In 2021, the UIF received 139,524 suspicious transaction reports, over 10 times the number of reports transmitted in its first year of activity. Despite the significant increase, thanks to careful management of the work processes, the ratio between reports received and those analysed and disseminated remained substantially stable compared with previous years.
The continuing pandemic had a considerable impact on active cooperation and on the analysis process. Misappropriation of public funds and fraudulent behaviours in connection with the exchange of the tax credits awarded under the emergency legislation were amongst the most frequent typologies encountered. In April 2022, the UIF published a specific Communication aimed at alerting obliged entities to the risks associated with potentially illicit use of such exchanges as well as forewarning general government entities and other obliged entities involved in various ways in granting funds in accordance with the NRRP, with the goal of encouraging their reporting for anti-money laundering purposes.
Cooperation between the UIF, the judicial authorities and the investigative bodies remained considerable, with 510 requests transmitted. The most important concerned the analysis of financial flows intercepted in complex cases connected to the health emergency, hypotheses of organized crime, offences against the public sector and fiscal frauds/crimes, also linked to the granting of tax credits. In 2022, a new Memorandum of Understanding was signed with the European Public Prosecutor’s Office (EPPO) to facilitate interactions between the parties. The MoUs with the National Anti-Mafia Directorate and the Customs and Monopolies Agency have been updated, while an additional Memorandum of Understanding was signed with Cassa Depositi e Prestiti SpA.
The exchange of information with foreign FIUs continued to be significant, providing substantial aid to both financial analysis and cooperation requests from the investigative bodies and the judicial authorities. In September 2021, the migration of the FIU.NET network from Europol to the European Commission was completed, opening up a planning phase for the development of an infrastructure able to sustain both the increasing information flows exchanged and more advanced forms of cooperation, such as joint analysis. Looking ahead, the presentation of the AML Package by the European Commission, which envisages among other things the institution of the European Anti-Money Laundering Authority (AMLA), which will act as the European anti-money laundering supervisor and the European Support and Cooperation Mechanism for European FIUs, was particularly noteworthy.
As regards strategic analysis, the SARA database was enriched with the addition of new information thanks to the lowering of the reporting threshold from €15,000 to €10,000, and with new reporting entities, such as the central points of contact for providers of payment services. The UIF continued its survey work on cash circulation, focusing on verifying its relations with the whole of the underground economy as well as on businesses at risk of being infiltrated by organized crime, refining the results already achieved by using machine-learning techniques.
The UIF supports the operators in applying the freezing measures issued as a result of the dramatic consequences of the invasion of Ukraine, facilitating the dissemination and awareness of the subjects listed in the European measures currently being issued. In two Statements published in March 2022, the UIF, alongside the Bank of Italy, Consob and IVASS, called for the operators to comply with the sanctions, urging them to notify the restrictive measures applied before the end of the maximum period allowed. The Financial Security Committee tasked the UIF with building a database on deposits over €100,000 held with Italian credit institutions in the name of Russian or Byelorussian citizens, in accordance with the European provisions.
